15 February 2019

The Banking Royal Commission’s final report was released recently with 76 recommendations. Among them, the report has set out in detail how and when so-called processing or administrative ‘errors’ veer into misleading or deceptive conduct and the need for corporations to have in place processes that avoid these systemic errors. The report also recommends that there should be one person in every bank that is responsible for the design and implementation of each product, keeping it fit for purpose, and if something goes wrong, remediating it. This implies having specific senior executive owning each of the enterprise processes, designing controls for these processes, and overseeing these checks and controls ensuring they are working without failure.